Número total de comentarios: 32

Ireland welcomes the publication of the first draft of the Global Strategic Framework for Food Security and Nutrition, which is to become the single reference for core priorities in relation to food and nutrition security. It is important that this document be a dynamic instrument that reflects the changing nature of global challenges. It is also important to include civil society in the formulation of this document. This is one way that future editions of the GSF will add value. We would like it to become a useful tool for decision-makers and policy makers in donor countries and development agencies. An executive summary and a concluding chapter that prioritises recommendations and expands on the required next steps would also help to add value and to make the document more user-friendly.
Nutrition
There is much in the current draft in support of the right to adequate nutrition (e.g. in paragraphs 34, 44, 47, and 63). We note, however that the definitions of the right to adequate food used in paragraphs 14 and 15 do not include any mention of nutrition. The CSF definition is broader than this and there is currently a discussion process to re-define the terminology. Nutrition security includes the right to an adequate diet or to nutritionally adequate foods, providing all the nutritional elements an individual requires to live a healthy and active life, and the means to access them.
Precise definitions are required in the definitions section for the terms food security, nutrition security, (paragraph 63) and food and nutrition security (paragraphs 26 &amp;amp;amp; 38) malnutrition (paragraphs 1, 5, 18-21, 31, 35, 46, 61, 72, 75-77, 94 &amp;amp;amp; 98) and undernutrition (paragraphs 12, 63 &amp; 90).
Malnutrition in children leads to many other problems, including stunted growth, poor educational attainment and lower future labour productivity. The CSF definition of food security recognises the role played by nutrition. However, we would like to see this role given a more prominent position by the use of the term food and nutrition security. Food and nutrition security is, therefore, a broader and more holistic term than food security and adds the aspects of caring practices and health services and healthy environments to the food security definition and concept. In other words, as stated in paragraph 65, we want to give the nutrition dimension more visibility. In this context we welcome the work of the CSF in analysing the terminology and we look forward to a suitable definition in the near future.
Dealing with the causes
The GSF sets out clearly (in paragraph 19) the main causes of hunger and malnutrition. Many of these are being addressed by the CFS. The Voluntary Guidelines on Land Tenure will increase security for smallholders, particularly women farmers. The reform of the FAO will tackle some of the lack of coherence in policymaking. But there is still insufficient attention paid to the role of women and the many forms of legal and cultural discrimination they suffer. A lack of purchasing power, political instability, weak institutions and nutrition insecurity are also serious challenges. The Rapid Response Forum will seek to address some of these issues in areas of natural hazard or disaster. But Ireland also holds strongly to the principle that prevention is better than cure. For this reason the Scaling Up Nutrition (SUN) initiative is critical to eliminating the many consequences of nutrition deficits. We also recognise the importance of access for smallholder farmers, especially women, to well-functioning markets and trade. This should include training and investment to reduce the high levels of post-harvest losses and food waste. And of course local communities must be closely involved in the design, planning and implementation of programmes. Smallholder farmers, many of whom are women, play a central role in producing most of the food consumed locally. The FAO report on the role of women in agriculture shows clearly that assisting women farmers could substantially increase the amount of locally-available food.
Education
Ireland believes that helping smallholders to help themselves is a vital part of any food and nutrition security strategy. Smallholders need assistance in implementing technology, preserving the environment, eliminating food and post-harvest waste and finding routes to market. Such training can include dealing with food markets, transportation, processing and the formation of partnerships and farmer cooperatives. Ireland has unique experience in building cooperatives and in this year of the cooperative we would like to promote this model as a dynamic way for smallholders to meet the challenges of harvesting, storing, processing and marketing their produce.
Increasing agricultural productivity
Paragraph 59 should highlight the need for biofortification and encourage smallholder farmers to diversify to more nutritious crops and to use climate-smart techniques such as drip-irrigation. We welcome the prominence given in this first draft to the need to support agricultural research. However, more emphasis should be placed on putting agricultural research outputs into practice through building partnerships between smallholder farmers organisations/associations, research organisations, non-governmental organisations and the private sector.
Economic impact
A new paragraph could be inserted before the current paragraph 60 to explain the economic case for investing in nutrition. This should emphasise the fact that nutrition plays a fundamental role in economic growth and development. Many countries lose 2-3% of their gross domestic product to undernutrition. Children achieve less at school and their productivity and health in adult life is affected. Adults affected by undernutrition earn up to 20% less. Up to one in three people are estimated to suffer from hidden hunger in some regions, resulting in impaired mental development, disease and death Therefore, in global terms, billions of dollars are lost in forgone productivity and avoidable health care spending.
Reducing volatility
Ireland supports the AMIS and Rapid Response Forum initiatives agreed by the G20 last year. These initiatives will help in planning for shortages and targeting aid where it is most needed. Ireland is concerned about price volatility and its impact on food production. Farmers will not produce if they don&#039;t know whether they can sell their products. They are suffering from high input costs, for feed, fertilizers, pesticides and energy. These high costs mean that farmers are not benefiting from high commodity prices. If prices are volatile, farmers cannot plan their costs and their production. Sustainable input prices and less volatile agricultural commodity markets are essential for food and nutrition security. In addition, high input costs will particularly affect women farmers where they have difficulty in accessing credit.
Gender in food and nutrition security
The FAO estimates that the undernourishment in developing countries could be lowered by 12-17% if the gap between men and women in access to inputs was eliminated. In addition, Women generally suffer more from undernutrition than men. But a women&#039;s nutritional status is critical not just to her own health and ability to maintain a secure livelihood. Babies in the womb must be properly nourished and the first 1,000 days of a childs life are critical in terms of nutrition. Ireland strongly supports measures to improve nutrition and to ensure equal access to productive resources for women. Laws are not enough in this regard without compliance monitoring. In addition there are indicators that could be used to monitor progress, such as improvements in nutritional outcomes, gender impact assessments, targeting education programmes to the needs of women, ensuring access to credit and supporting cooperatives with female involvement at all levels. We encourage the use of consistent references throughout the document to both access and control of resources such as land and credit as we know that although women may formally have access to a resource, in reality they might not have a role in decision-making on how that resource is used.
Core actions
Although the GSF provides recommendations for governments, Ireland believes that Civil Society must also look to this section for guidance as to best practice. In particular, the recommendation to incorporate objectives, targets, benchmarks and timeframes as well as actions to formulate policies, identify and mobilize resources, define institutional mechanisms, allocate responsibilities, coordinate the activities of different actors and provide for monitoring mechanisms could also apply to NGOs, who are after all partners with governments in the CSF. Providing assistance is only half of the battle. Monitoring outcomes to improve future projects is also essential. Indeed, the same recommendation could be made in relation to gender assessment, given that sex-disaggregated data is so scarce.
Improving global support
It is envisaged that the GSF will highlight other issues of importance where currently no universal or broad consensus exists as yet, where further work is needed and where there are gaps in policy convergence. Ireland believes that the SUN initiative should be included in paragraph 86 as a key element to ensure food and nutrition security. Suggestions for wording could include:
-Scaling Up Nutrition: Countries with high burdens of undernutrition should join the SUN movement, commit to scale up their efforts to combat undernutrition, and raise the profile of nutrition within their respective national strategies and programmes, aligning their resources accordingly. Donor governments and other relevant stakeholders should also become actively involved in the SUN movement, to coordinate their efforts to respond to country requests for support to scale up nutrition, and to increase their financial and technical support.
-Cross-cutting measures: Countries should adopt a multi-sector approach that integrates nutrition across multiple sectors - including agriculture, health, water and sanitation, social protection and education - to achieve improved nutrition outcomes at household level; and
In this regard, Ireland strongly advocates for the inclusion of a paragraph on the SUN movement in that part of the GSF which highlights other issues of importance on which no universal consensus exists as of yet. There are already 30 countries supporting the SUN initiative and the broad principles of the initiativeÃ�Â¢Ã¯Â¿Â½Ã¯Â¿Â½ finding successful ways to end world hunger - are the same as that of the GSF.
Achieving results
We are happy to see, in paragraph 95, the statement that Accountability for results is crucial and also that objectives to be monitored should include nutritional outcomes. The principles set out in the following paragraphs are helpful. The need for sex-disaggregated data is also mentioned in paragraph 96. We are also happy that results-based management principles are seen as an important element and that evaluation should be included. Once again, however, this should be portrayed as applying not just to Governments and international agencies, but rather to all stakeholders, including NGOs that are our partners in the CFS process.
Summary
Ireland is pleased that the process of formulating a Global Strategic Framework for Food Security and Nutrition is underway. We would like to see:
-Less reliance on stating previous reports and clear statements on how the GSF will add value;
-A more user-friendly document that includes an executive summary and a concluding chapter that includes recommendations and next steps;
-A focus on action-oriented collaborative projects involving all stakeholders, i.e. putting research into use;
-A focus on outcomes and result-based monitoring and feedback rather than on inputs;
-The inclusion of a paragraph on the SUN initiative, perhaps in paragraph 86 of the first draft of the GSF;
-Continued efforts to ensure that the role of women smallholders is recognised and their rights defended; and
-Strong support for AMIS and the Rapid Response Forum in the fight to prevent excessive price variability.

Dear Moderator,
Important gains have been made on coherence on global process regarding food security. The Global Strategic Framework is an effort to bring those agreements together in one place. There is an emerging consensus on the need to redirect efforts to farming and fill the gap of many years of neglect for the sector in development assistance and national budgets. Thank you to all for their efforts to compile this document
1- As per its mandate stated in paragraph 1, the International Agri-Food Network would like to re-emphasise that the role of the Global Strategic Framework is to provide a compilation of existing decisions. In that light, we would recommend that it references existing UN agreed language, rather than language from non-agreed documents. For instance, paragraphs 69 and 70 should be replaced by language from the Voluntary Guidelines on Land Tenure, which the CFS just finalised.
2- In the same vein, reports and documents referenced in the text should be those that represent consensus among UN members. There are several mentions of reports, such as the ICARRD and IAASTD in paragraphs 11, 13, 36, 69 and 70, which are not UN consensus documents. In addition, the reference to these documents excludes mention of several other useful reports - such as the Foresight Report or the World Bank Development Report of 2008 - which should also be considered if those other reports are mentioned.
3- Furthermore, we would suggest that in the interest of ensuring the Global Framework does fulfil its purpose as stated in paragraph one, that it is to compile agreed decisions, the section on &#039;gaps&#039; (paragraphs 71-74) is not appropriate. Listing non-agreed items does not help achieve consensus or build a strong framework focused on action.
4- The Network suggests that further emphasis on building long-term resilience, with particular focus on women farmers, and on restoring and strengthening knowledge sharing mechanisms such as extension services, would be positive and should be taken up more fully in the text.
Line by line comments were submitted last month to the secretariat during the course of the regional meetings.
Best regards,
Robynne Anderson
Secretariat to the International Agri-Food Network

In line with the &amp;amp;quot;Guidance Note for the review of the First Draft of the Global Strategic Framework for Food Security and Nutrition (GSF) at the 2012 FAO Regional Conferences&amp;amp;quot;, the undersigned Civil Society Organizations from Switzerland, bring the following messages to your attention. We broadly support the &amp;amp;quot;Summary assessment of GSF first draft from a civil society perspective&amp;amp;quot;, developed by the Civil Society Mechanism available online. In addition to these more detailed messages, we would like to invite you to consider inclusion of these aspects in your position as appropriate.
Please see attachment for detailed comments.

Best greetings again from the CSM Task Team on the GSF. Please find enclosed the final version of the Contributions from CSO consultations at regional conferences on the GSF First Draft.
The document is a synthesis from civil society contributions to the questions raised by the CFS Secretariat on the GSF first draft online consultation. A Draft version was already posted on this platform by Natalia Landívar on May 9.
It is the result from contributions compiled during civil society consultations held in the frame of FAO regional conferences in March and April. A range of civil society actors had the opportunity to hold regionally specific discussions in Hanoi, Buenos Aires, Baku and Brazzaville on the main aspects of the GSF first draft based on a summary assessment prepared by the CSM Working Group on GSF. The contributions from the Beirut meeting were posted directly to the online consultation website, in Arabic language.
The purpose of this synthesis is to support the CFS secretariat with a precise and comprehensive document, by
a) Identifying the main common points of concern and joint proposals of civil society organizations gathered at the regional consultations regarding the GSF, along the lines of the four questions raised by the secretariat (Page 2-16);
b) Compiling in the annexes of this document the different documents that have been elaborated by members of the CSM working group on GSF or by the regional consultations of civil society, with particular relevance for the GSF draft two (page 17-52).

I do share the view that the Global Strategic Framework on Food Security and Nutrition needs to build upon previous work done in context of CFS and other sources of relevance to global food and nutrition security. However, there needs to be a balance in how these existing instruments are mainstreamed into the GSF. The current version of the GSF looks more like a compilation of key decisions and recommendations of existing initiatives and programmes. This appears to be in line with the guideline (bullet 1) that the “… the first Version (of the GSF) should therefore focus on the most important agreed decisions and frameworks”. Unfortunately, this way, the GSF becomes a summary of various decisions and CFS instruments on food security and nutrition, rather than a central cohesive framework.
My problem is that the document, as it presently stands doesn’t seem to have a ‘heart’. It has a lot of hands and legs – and probably also a stomach; but I am missing the heart! The heart of the framework must be the central frame, to which relevant existing instruments and initiatives could be aligned. Without such a central ‘frame’, the draft document does indeed look like a compendium of food and nutrition security agreements and documents, with diverse foci and recommendations. The closest the document comes to producing a ‘heart’ is Section IV on “Policy, Programme and other Recommendations”. These programmes and recommendations are organized according to a number of selected studies and existing instruments (VGRtF, RAI, Food Price Volatility, Gender in Food Security and Nutrition, Tenure of Lands, Fisheries and Forests, etc.). These are all useful for the GSF, but I think they need to be structured differently, such hthat key elemnst from these may contribute or align with the framework. Merely listing them and providing summaries of what they consist of, does not amount to a framework, in my opinion.
I must apologize for putting things in such a blunt manner; but let me go on and attempt to make some suggestions. First I will suggest a slight modification (rearrangement) in the structure of the document. Subsequently, I would attempt to answer the specific questions that have been requested to be answered:
PART 1
With regard to the overall flow of the document, I would like to propose some changes in the current content flow:
Section 1 on Introduction and Background – This should consist of
o CFS: should begin with the CFS and its reform outcomes (as indicated in paragraphs 6-9), and leading to the need for a GSF
o GSF: Introduce the GSF (as currently attempted in paras 3,4 and 5; and also in para 10 and first line of para 11). The section should also answer the question “What is the GSF?” - I do not see that clearly in these sections. Perhaps one could say something like: The GSF is a holistic multi-stakeholder framework of agreed priorities, programmatic components and implementation strategies, for ensuring effective policies and programmes in support of global food and nutrition security at all levels.
Section 2: Food Security and Nutrition
It is important to give adequate visibility to this as it is the principal theme of the GSF document.
o This section should introduce the Food Security concept and its association with Nutrition. It will include some of the content under heading of “Definitions” in current document.
o It could also borrow content from the very useful historical trend analysis done by the CFS Food Security Terminology Task Team (not in terms of their recommendation, but the factual and historical account given)
o The root causes of hunger and challenges ahead: This should reflect the three aspects indicated in current Section II, but with each of them critically reviewed to reduce overlaps and make them more targeted and much fewer than current listing.
Section 3: Overarching Frameworks related to Food and Nutrition Security
o This is currently covered in section III, and in part, also in section IV. There needs to be some discussion on which frameworks need mention and introduction in this section. My suggestion is that it is useful to mention a broad number of frameworks, with a brief introduction of each, but not getting into the details of principles, actions, recommendations, etc.
o I suggest that the UN HLTF Comprehensive Framework for Action could also be added
o These frameworks are to be presented as building blocks taken into account in the development of the GSF. None of the frameworks by themselves provide “an overall framework for food security and nutrition” as indicated for the VGRtF (see para 23). The GSF when put together will provide the overall framework on food security and nutrition – and it will be influenced by a number of existing frameworks and initiatives.
Section 4: The Elements of the GSF
(Sections 4 and 5 constitute the ‘heart’ of the framework. Section 4 describes the vision, purpose and principles of the GSF; while section 5 will deal with the programmatic frame for the GSF)
o Statement/Description of the GSF vision on:
o The state of global food and nutrition security that we expect to see (2020? 2050?)
o The role and contribution of CFS and its contribution to global food security
o The nature and purpose of the GSF (points below are just examples, for illustration):
o To be a living and strategic instrument to guide policy and programming in food and nutrition security at country and global levels
o To provide guidance on elements for incorporation in national and regional food and nutrition security strategies
o To guide the functioning and the monitoring of CFS food security activities
o Principles and Lessons Learnt
o These would include underlying principles driving the GSF as well as Lessons Learnt from previous experience
o The principles section should borrow from some of the overarching frameworks, described in sections III and IV of the current draft. They could include issues like:
o Nutrition as core part of food security; there cannot be food security without nutrition
o Attaining FN security involves more than just agriculture; it requires multi-sectoral approach at all levels
o Sustainability should be a key component in agriculture and food security programs, at all levels (smallholder and large scale initiatives)
o Etc., etc.
Section 5: Programmatic Components of GSF
o The twin-track approach:
o Direct immediate action
o Medium / Long term action
o Production at multiple levels/systems
o Smallholder systems
o Medium/Large scale intensive production systems
o Crosscutting elements with relevance at all scales of production:
o Dealing with nutrition
o Sustainability / environment al health
o Resilience of systems and livelihood options
o Productivity and production /
o Loses and wastage in agriculture and food systems / IPM, postharvest, etc.
o Value chain / markets / processing
o Policies; Etc., etc.
o Implementation Issues
o Smallholder farmers
o Gender and women
o Youth in agriculture
o Etc., etc.
Section 6: Uniting and Organizing to Fight Hunger (based on section V of current draft)
PART 2
In the second part of my commentary, I wish to do what we were requested to do in the first place: focus comments on the specific questions posed.
Question 1: Does the First Draft present key issues of food security and nutrition on which there is broad regional and international consensus?
Yes, I think it does. However, as explained above, I am uncomfortable with the way it has been packaged, simply as a compilation of various decisions and study recommendations from past CFS documents.
Question 2: Does the list of areas where there are gaps in policy convergence that may be addressed in future versions of the GSF need to be amended?
Yes. I believe gaps in policy convergence implies that there are opposing positions on those issues. An example would be the role of biotechnology, or more specifically GMOs, in contributing to food security. However the listing in the document includes a number of issues on which there is no gap in policy convergence, but rather lack of implementation, or a gap in implementation. Some examples of the latter are ‘need for a value-chain approach’, the ‘need to boost rural employment’, ‘finding ways to improve effectiveness of regional organizations’ etc. I do not think these fit under GAPS IN POLICY CONVERGENCE. They are probably areas requiring more efforts in implementation or in policy action!
Question 3: Does the document have sufficient practical regional and country-level relevance? Can you suggest improvements?
Yes. All the issues raised have practical regional and country level relevance. Additionally the paragraph 78 of the draft document “Core actions at country level” provides a set of recommendations that could be considered by countries. Similar set is developed for the regions in paragraphs 79-84. The two sets would need to be further refined to make them come out as proposals for action, upon which monitoring could be done in the fute.
Question 4: How can the GSF be linked to regional and national food security and nutrition frameworks and strategies, and accountability and monitoring mechanisms, in ways that promote two-way coordination and convergence?
If the GFS is successful in highlighting key priorities of relevance to countries and regions, and also providing strategic direction in support of food and nutrition security development, it will be actively sought and used by countries as reference document and as model and guide. The usefulness of the GSF would be defined on the basis of its use by countries.
The GSF could also include some indicators that could be used to assess the value and usefulness of the instrument.
Conclusion
The Task Team has done a good job at highlighting the key issues and putting it all together into this Draft. I believe that comments received from various sources will add even more value to the document and orient it towards becoming a holistic framework on Food and Nutrition Security for the CFS.

Comments to Global strategic framework
1. Does the First Draft present key issues of food security and nutrition on which there is broad regional and international consensus?
In broad terms yes, the First draft presents the key issues in a good way. I especially welcome the reference to IAASTD, along with other important documents (para 11 and 13) and the list of lessons learned (para 21). Para 32 on medium/long term actions to address the root causes of hunger is short but still captures the key actions that are needed. However, there are also some important gaps. First, to the list of structural causes of hunger (para 19), not enough attention is paid to environmental issues such as degraded soil, reduced biodiversity and degradation of several other ecosystem services on which agricultural production is dependent. As for now, degraded eco-systems are only mentioned in the context of climate change, not as a cause in its own right.
Likewise, in the list of emerging challenges (para 20), I would like to see the following challenges added:
- The loss of soil fertility, as well as several other ecosystem services on which agricultural production is dependent.
- The need to reduce GHG emissions from agriculture.
Similarly, the paras on increasing agricultural productivity in a socially, economically and environmentally sustainable manner (para 57-58) lack a recognition and analysis of the severe environmental problems resulting from current (unsustainable) agricultural practices.
Second, to the list of lessons learnt (para 21) we would like to add that cash transfers in the context of social protection systems have proved to be effective in reducing malnutrition and poverty.
Third, the recognition that “agro-ecological approaches have proved to be key to improving agricultural sustainability as well as the incomes of food producers and their resilience in the face of climate change” (para 21, lessons learned) should be reflected in the recommendations. I therefore suggest
- A direct reference to agro-ecological approaches in the second bullet point of para 39 (list of actions needed to increase smallholder-sensitive investment in agriculture).
- add an extra bullet point in para 59: “Promote the use of agro-ecological approaches that are key to improving agricultural sustainability as well as the incomes of food producers.”
Finally, the recognition of the potential of agro-ecological approaches, as well as of IAASTD findings about the need for more inclusive and participatory agricultural research and development, should be reflected in the recommendations on agricultural research and innovation. I therefore suggest that in the context of research and development (para 39, last bullet point and para 40, second bullet point) it is stated that there is a need for increased research about agro-ecological approaches, and that in order to be relevant for farmers and local conditions, research and development need to involve farmers to a greater degree than previously.
Similarly, in para 59 it should be added (fifth bullet) that publicly funded research and extension services need to prioritise the development and promotion of low external input technologies that are environmentally sustainable and profitable for the individual farmer, but where there are few companies that have a business interest in promoting the technologies.
Along the same lines, in para 86, we suggest the following addition: “…capacity development and transfer of technology, especially low external input sustainable agriculture and agro-ecological approaches”.
2. Does the list of areas where there are gaps in policy convergence that may be addressed in future versions of the GSF need to be amended?
I would suggest the following areas to be added to the list:
- The relative priority that should be put on research, development and extension on low external input and agro-ecological approaches vis a vis high input, conventional industrial farming models.
- Whether agricultural production based on agro-ecological approaches would be sufficient to feed the world population today and in the future.
- Whether dietary habits, especially as regards meet consumption, will have to be changed in order for the future challenges of climate change mitigation, increasing competition for land and other natural resources, and food security to be met.
- The degree to which unfair trade rules, unfair trade practices and unethical business practices contribute to hunger.
A few specific comments:
Para 35. In the para on social protection, a reference to the Social Protection Floor Initiative should be made.
Para 52 (first bullet): “Improved analysis and understanding of countries’ and local populations’ need will be instrumental….”
Para 53 (third bullet): “…e.g. through conservation agriculture and agro-ecological approaches”
Para 93. I suggest the following addition: “Local and national bank, including microfinance institutions may be usefully involved…”
Ms Gunnel Axelsson Nycander, May 11th
Policy Adviser on food security, Church of Sweden
Chair of APRODEV working group on Trade, Food Security and Gender
Member of Ecumenical Advocacy Alliance (EAA) Food Strategy Group

Concern Worldwide welcomes the development of the Global Strategic Framework. It is a central component and tool to realising the vision of the Committee on World Food Security (CFS) as well as to ensure achievement of its mandate. The First Draft of the Global Strategic Framework (GSF) outlines the comprehensive vision of the CFS as the foremost inclusive forum for global governance of food security and nutrition, with the GSF providing an overarching framework to guide and enhance coordination and coherence. As such, it is important that the GSF clearly states that it should serve as a guide for ALL stakeholders that have a role in ensuring food and nutrition security. This includes the private sector, multilateral institutions and international organisations and civil society.
1. Does the First draft present key issues of food security and nutrition on which there is broad regional and international consensus?
i) The first draft contains a much greater focus on nutrition than previous iterations, which is very welcome and highlights the growing recognition within the CFS of the importance of nutrition and its integration within a comprehensive approach to realising the right to food for all. As such, Concern feels it would be important to make reference to the Scaling Up Nutrition (SUN) movement (potentially in both section III and V). Over 100 agencies and organisations have endorsed the Scaling Up Nutrition (SUN) Framework and roadmap. SUN represents an unprecedented global consensus and effort to improve maternal and child nutrition during the window of opportunity, from a woman’s pregnancy to a child’s second birthday. It incorporates and embodies a number of the components that are already highlighted in the First Draft, such as a twin track approach, and the need to address nutrition concerns through both direct interventions and through the adoption of nutrition sensitive approaches. The SUN focuses on implementing evidenced-based direct nutrition interventions and aims to address the underlying causes of food security and nutrition by integrating nutrition goals into broader efforts in critical sectors such as health, social protection, and agriculture.
In addition, as a movement, SUN brings organizations from across all relevant sectors together to support national plans to scale up nutrition. Central to the SUN Framework is the recognition that the real work will take place, and needs to take place, at the country level. Emphasis is given in the First Draft to the importance of strengthening multi-stakeholder and inter-ministerial mechanisms, establishing networks of stakeholders and accountability structures to take responsibility for nutrition commitments and objectives, as well as to high level political commitment to ensuring sustainable efforts to address malnutrition. The SUN provides an example of how stakeholders are combining efforts to realise and maintain these crucial elements.
ii) More emphasis and clarity should be given to the social determinants of malnutrition, including access to safe water and sanitation, maternal and child care, and quality health care, reflecting the multiple and connected causes of malnutrition as laid out for example in the UNICEF causal framework on malnutrition. Gender equality is also imperative in making progress on undernutrition. The health and social aspects as well as gender inequality in relation to nutrition status should be brought out more in section II. It would add clarity for the GSF to state that the scope of the framework is to look at food security and nutrition, and in this context it will help ensure that nutrition includes these social determinants.
iii) The World Health Assembly is shortly to adopt an implementation plan on Maternal, Infant and Young Child Feeding (at the end of the WHA in May). Several global targets will be included in the plan. It would be useful to refer to this initiative underway.
iv) Sustained political commitment and reporting against these commitments will be imperative to tackle the scourge of food and nutrition insecurity facing the world today. Commitments on food security were made at the G8 summit in L’Aquilla in 2009, Sustainable Development Goals will be discussed at the Rio +20 conference in June, and discussions are already underway in relation to a post 2015 framework when the deadline for achievement of the MDGs is reached. The failure of donors to deliver on their past commitments needs to be addressed (this issue could potentially be addressed and reflected in section V C). Given the various initiatives underway, it is important that food security and nutrition remains a priority on the political agenda, that donors recognise the need, and seize the opportunity for, a new multilateral commitment on food security and nutrition.
v) It has become increasingly recognised that there is lack of coordination and flow between interventions and funding for emergencies and longer term development measured against food and nutrition security targets. The recurrent use of food aid with insufficient attention given to how this undermines or reinforces local agricultural resilience and local initiative serves to exacerbate and cause food insecurity. Much greater attention and resources should be given to ensuring effective post-emergency rehabilitation to ensure that local agricultural resilience and local initiative are strengthened. The continuing use of donor sourced food aid can undermine these efforts and should be avoided in these situations. When relief activities are tied to development objectives, development programmes can serve to protect people’s assets more effectively and reduce the need for relief in response to shocks.
In addition, emergency food assistance should be carefully integrated into national food and nutrition security plans to ensure that food or food-related transfers do not undermine other aspects of food security and take account of the importance of ensuring nutritional status of women and children is protected and considered in emergency as well as development contexts.
The GSF should further consider the type and quality of emergency interventions such as food transfers, as well as the modalities of interventions (vouchers/cash/direct food, reserves), recognizing the potential and preference for a move towards cash where there are functioning markets in order to strengthen local markets.
These above points should be stressed particularly in section V covering uniting and organising to fight hunger.
vi) Concern welcomes the recognition of social protection as a key pillar in addressing the underlying causes of nutrition and food security, as well as the acknowledgment of the need to move from adhoc, stand alone, donor-driven programmes towards social protection systems. Also welcome is the recognition to move from emergency transfers to long term, predictable assistance with a focus on vulnerable groups. The GSF appears to focus mainly on social assistance however. The CFS should in addition, explore the opportunities and potential of social insurance mechanisms such as weather-index micro-insurance for small holder farmers. Linked to this – it would be important to emphasise social protection in light of the increasing frequency and severity of shocks related to a changing climate. The opportunity that the GSF presents should be used to emphasise the protective, preventative, promotive and transformative benefits of social protection, and the importance of policy linkages to ensure these benefits are leveraged (e.g. social protection plus policies supporting vocational training and employment to enable realisation of ‘promotion’ (i.e. cash transfers support households to increase their productive or economic potential).
vii) We welcome the point on social protection scale-up in an emergency. For this to happen smoothly there is a need for delivery systems to be accessible to the poorest. Electronic payment systems are proven effective but their reach remains limited in many rural areas. It would be good for the CFS to recognise this and to make comment as to if and how they could have a role in leveraging for systems development.
Cash transfers are proving to be a more appropriate modality than food aid for achieving food security. Many donors and humanitarian agencies are increasingly using cash transfers as a form of food assistance in times of humanitarian emergency . Under the right conditions and with functioning markets, cash can assist extremely poor and vulnerable households to meet basic needs, and prevent negative coping strategies, such as selling assets, removing children from school, or pursuing risky ways to earn money. A review of cash transfers by the UK Department for International Development (DFID) shows that households receiving cash transfers are likely to spend it on improving the quantity and quality of food consumed . In Zimbabwe and Malawi, Concern also found that cash transfer recipients consistently consumed higher-quality diets than those who received in-kind food aid . While the evidence is mixed for improving nutrition through cash transfers in emergency contexts, results from Concern’s interventions in Niger indicate that cash plus other interventions, such as Community Management of Acute Malnutrition may be more likely to be successful since they address the multiple underlying causes of malnutrition.
viii) Throughout the document social protection is used interchangeably with ‘safety nets’. This should be removed. It has connotations of emergency assistance and of protection only – whereas social protection is more than just a safety net.
ix) In relation to past experiences and lessons learned, this section would be enhanced by making it more evidence-based, with footnotes to illustrate where data and statements have been used. Great examples from Brazil, Mexico and Ghana are missing here where governments have successfully reduced food insecurity and undernutrition.
2. Does the list of areas where there are gaps in policy convergence that may be addressed in future versions of the GSF need to be amended?
i) Throughout the document the terms ‘food security and nutrition’ are continuously used. However, while a definition for ‘food security’ is provided, there is no clear definition for ‘nutrition’ ‘undernutrition’ or ‘nutrition security’. The interlinkages and distinctions between the terms are not clear and each term contains differing meaning. At the 37th Session of the CFS, called on the Bureau to propose options on the meaning and different uses, if any, of the terms "Food Security", "Food Security and Nutrition", "Food and Nutrition Security" and "Nutrition Security" to the CFS Session for the standardization of the official terminology that the Committee should use.' (CFS/37, 2011). Reference should be made to this ongoing discussion and upcoming decision on nutrition terminology. This will be necessary for ensuring that the agreed standardised term will be used in subsequent versions of the GSF as well as in other policy documents stemming from the work of the CFS.
ii) The First Draft highlights a number of areas where there has been insufficient attention given to creating an environment conducive to robust food security. Among this list, the lack of integrated programming and approaches that persists, should be added, which serves to limit holistic responses to food security and nutrition.
An additional area that would be important to include under this section would be the role of the private sector and multilateral organisations in addressing food security and nutrition, recognising that the private sector is a heterogeneous group, and the need for regulation to ensure that private sector investments and actions have optimum positive effect, are conducted in a transparent way, and ensure any potential negative impacts are avoided.

IBON International welcomes the inclusive approach of the Committee on World Food Security (CFS) in the development of the Global Strategic Framework (GSF) and forwards initial comments on the first draft:
Section III: The foundations and overarching frameworks
• A rights-based approach to food security as expressed in the right to food is indispensible. To this aim, it is positive that the Voluntary Guidelines to support the progressive realisation of the right to adequate food in the context of national food security is included as an overarching framework. However, we recommend that the GSF go further to include food sovereignty as part of the foundations to achieving the right to food. Food sovereignty is a widely recognised concept, which has already been adopted in several countries’ legislative frameworks including Bolivia, Ecuador, Mali, Nepal, Senegal and Venezuela. It would provide for the structural causes of poverty and hunger to be rectified by providing for national and peoples community ownership of sustainable food production and distribution. The UN Special Rapporteur on the Right to Food, Olivier de Schutter, endorses local production and self-sufficient in food production which is a key element of food sovereignty.
Section IV. H: Tenure of Land, Fisheries and forests (para 68 – 70)
• Between 2000 and 2010, 203 million hectares of land have been subject to foreign land acquisitions. These land acquisitions only fuel further food insecurity as agricultural production is primarily intended for export and for biofuel production. Local populations are also displaced from the targeted areas and their agricultural productivity for local markets is erased as well as increasing the number of poor and food insecure. Ancestral domains of indigenous communities are also severely impacted. Given the significance of these foreign land acquisitions and negative impact on domestic food production, the absence of acknowledgement of foreign land acquisitions in the GSF is stark.
• We recommend that para. 70 on the recommendation for countries to consider establishing legal and other policy mechanisms that advance land reform to include a specific reference against large-scale land acquisitions which may have severe ecological, social and economic impacts, and for those countries which already have these mechanisms in place, a recommendation to review these policies and institute strong regulatory mechanisms on their impact on local communities and the environment.
• Legal frameworks in the countries in question should also be strengthened to rein in the unchecked commodification of communal natural resources.
• There should also be included a recommendation that states involved in foreign land acquisitions should review all their foreign land acquisition deals to guarantee that there are no ecological, social and economic impacts in the country.
Section IV. I: Major Gaps in Consensus on Policy Issues
• While it is of great benefit to focus on policies that can be introduced to achieve food security, it is also necessary to consider policies that must be removed to achieve a real balance. We thus propose that par. 73 should be amended to include the need to remove all trade and production competition food subsidies in Northern Countries. These subsidies fuel poverty and hunger in developing countries as subsidised excess food is ‘dumped’ in Southern Countries at below market prices; subsidised fishing fleets harvest all available fish stocks in national waters using unsustainable methods that local fisherfolk cannot compete with. Harmful food subsidies need to be expressly condemned and there should be a recommendation for their removal.
• Policies which facilitate uncontrolled foreign land acquisitions should be removed. This includes the creation of enabling legal and political environments where foreign investors can invest in countries without any checks and balances. The unregulated foreign investment in Southern Countries has led to excessive depletion of natural resources including water, for example the Niger River is decreasing by 10% every decade due to intensive agricultural practices on its banks.
• It is important to explicitly address these issues in the GSF as many Southern Countries’ governments face strong pressure from International Financial Institutions, International Development Agencies and foreign Governments which limit their power to object to these policies.
• Small-holder farmers are rightly recognised as an integral part of agricultural production and should be supported. However, it is suggested that with the role of small-holder farmers in mind there should be a stronger regulatory regime on private investors in agriculture. This is in the context that private investors are the primary cause of displacement of small-holder farmers, for example in major land acquisitions and in competition for natural resources such as water.
• On price volatility, the causes of food price volatility are not adequately addressed and this is reflected in the following actions to reduce price volatility. The factors influencing the food price hike of 2008 were multiple but there are clear links to wild speculation in food prices, increasing demand for grains for biofuel production and reduced productions from the increasing frequency of extreme weather conditions. Opening trade flows as suggested in para 42. is unlikely to be of any benefit to national food production systems and it is more probable that this will have a negative impact on local food producers who need more protection of local production systems. Furthermore, the recommendation on biofuels should be stronger as there are clear linkages in the food prices hikes with biofuel production.
Section V. D: Making it happen: linking Policies and Programmes with resources
• Paragraph 91: International development assistance should not be premised on conditionalities to develop national ownership as enumerated in the Paris Declaration on Aid Effectiveness and the Accra Agenda for Action.
• Paragraph 92: loans and investments by International Financial institutions (IFIs) should not be subject to policy conditionalities. IFIs structural adjustment conditionalities have deepened existing food crises and in some cases caused food crises where previously there were none. Technical assistance provided should be demand driven and premised on selection and management of the developing country as the primary beneficiary and all recommendations should be subject to public consultations prior to approval in order to ensure that public interest is held above all.
• In order to achieve food security and develop sustainable agricultural systems, it is widely accepted that there must be adequate investment into agriculture. But previous experiences indicate that investment is limited. Public investment should take the lead and create interest and confidence for broader agriculture investment promotion.
Section V. E: Monitoring and Follow-up
• As it is explicitly stated in par. 95, ‘accountability for results is crucial.’ However, the approach recommended in paragraphs 95 to 101 emphasise monitoring and evaluation but lack sufficient accountability mechanisms. Mention of accountability systems is vague. Monitoring and evaluation strategies are useful in their own right but are insufficient to replace accountability mechanisms in which a state must answer to its citizens such as through public hearings and consultations. This section could give more country and regional level examples of accountability mechanisms including adopting legislation on the right to food and strengthening courts and other relevant adjudicating bodies where individuals and representative bodies can further hold the state accountable.
• The GSF should include a provision recommending that all states adapt their legislative frameworks to incorporate the right to food. This is a key step to ensuring that states are accountable for realising citizens’ right to food.
Capacity building and awareness raising
• The Global Strategic Framework is unlikely to be achieved without strong support and advocacy from civil society organisations and citizens. This requires awareness beyond specialised government and international agencies and a more general awareness and understanding of food security, the global strategic framework and mechanisms for its realisation at the national level. To achieve this aim, it is recommended that the GSF incorporate a section addressing capacity building and awareness raising as well as mobilization of public participation at the national and local levels.

Australia,&nbspEmily Collins, Australia, Estados miembros

General comments
The GSF attempts to collate existing frameworks on food security, highlight action required at country, regional and global levels, and outline the next steps to take. It thus positions itself as the ‘top of the tree’ in terms of action on food security and nutrition.
However, we note that the GSF is supposed to be a short, flexible and overarching document, outlining areas of agreement and consensus. Yet as it stands, this document is:
• More than 30 pages.
• contains references to a range of issues with which we don’t agree and where there is clearly no consensus
• gives little indication that this process will add value on what is an already congested issue
The document should be shorter, more succinct and less repetitive.
The GSF appears to be a time and resource intensive project. Australia encourages the CFS to conclude it as soon as possible and move on to other substantial work projects
Australia also has some specific comments that we would like to make.
The GSF recommendations for action are broken into two sections; those to which consensus has been reached, and areas where there are gaps in policy convergence.
In the consensus section on Actions to Reduce Price Volatility, the following actions (among others) are recommended;
• Improvements in market transparency, regulation and supervision of agriculture derivative markets.
• Relevant international organisations, in consultation with all relevant stakeholders, to further assess the constraints and effectiveness of creating and maintaining local, national and regional food reserves.
We note that appropriate (ie minimal) regulation and supervision of agriculture derivative markets was agreed in the G20 context.
Australia does not support inward-looking policies such as the maintenance of food reserves, as they are market distorting and, importantly, not effective. A landmark FAO paper from 2011 on Food Security in Volatile Global Markets (on page 225) concludes:
“[T]here is little evidence that buffer stock stabilisation did result in any significant reduction in price volatility.”
Australia notes that we only support well managed food reserves strictly for humanitarian purposes, not as a tool for price control.
In the gaps in consensus on policy convergence section, the following is noted;
• Seeking consensus on the definitions of the concept of “food sovereignty” and the “green economy”, and their implications for stakeholders
• Australia notes that we would object to any definition of “food sovereignty” that explicitly or implicitly restricted trade or promoted protectionism. The remainder of the GSF appears to be quite pro-trade, and this remains in the ‘to be agreed’ section, so is less of a concern.